PRIVACY POLICY

This Privacy Policy (hereinafter referred to as the “Policy”) defines the procedures for the collection, use, storage, and protection of information obtained by “HolyPoly” Limited Liability Partnership (“Partnership”) from individuals and legal entities (“User”) when using the Partnership’s website located at: https://scanwow.com/ (“Website”).

1. General Provisions

1.1. This Policy has been developed in accordance with the applicable laws of the Republic of Kazakhstan, the internal and public documents of the Partnership, as well as the requirements of international laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the OECD Privacy Guidelines, along with other applicable international treaties ratified by the Republic of Kazakhstan.

1.2. By using the Website, the User confirms their consent to this Policy and agrees to the collection and processing of their data in the manner and under the conditions set forth herein.

1.3. For the purposes of this Policy, the term “Confidential Information” refers to any information obtained by the Partnership from or about the User that:

1) Is not public, commonly known, or publicly available;

2) Constitutes their personal data;

3) Relates to the User’s payment information (e.g., card details, transaction numbers, etc.);

4) Represents the User’s commercial, banking, tax, or other legally protected secrets;

5) Pertains to the User’s purchases, preferences, and behavior on the Website;

6) Is recognized as such under the laws of the Republic of Kazakhstan and international treaties ratified by the Republic of Kazakhstan.

1.4. The Partnership does not verify the accuracy of the information received and/or collected about the User.

1.5. Certain sections of the Website, marked accordingly, are intended only for the Users aged eighteen (18) years of age or older. The Partnership does not knowingly collect information about minors and does not verify the accuracy of data provided by the User on their profile page.

1.6. If there is reason to believe that Confidential Information was obtained from a person under eighteen (18) years of age, such data will be deleted upon the first request of their legal representative.

1.7. Specific terms regarding the collection and processing of the User’s personal data are outlined in the Partnership’s Personal Data Collection and Processing Policy and/or any other similar document approved by the Partnership and published on the Website.

2. Procedure for Ensuring the Security of Confidential Information

2.1. The collection, use, storage, and protection of Confidential Information shall be carried out in accordance with the following principles:

1) Respect for constitutional rights and freedoms of individuals (human and civil rights);

2) Lawfulness of the purposes and methods of processing Confidential Information and good faith;

3) Confidentiality of the information provided by the User;

4) Compliance of the purposes of processing Confidential Information with the purposes defined and declared at the time of collection;

5) Ensuring the security of Confidential Information and prohibiting the merging of databases containing such information if created for incompatible purposes.

2.2. The Partnership shall take all reasonable organizational, technical, and legal measures to protect Confidential Information from unauthorized access, use, disclosure, alteration, or destruction.

2.3. Access to Confidential Information shall be granted only to authorized employees of the Partnership who have undertaken obligations of non-disclosure.

2.4. The Partnership may disclose Confidential Information to third parties exclusively in the following cases:

1) For fulfillment of its contractual obligations;

2) When expressly required by the laws of the Republic of Kazakhstan;

3) With the User's explicit consent.

2.5. To ensure maximum security of Confidential Information, the Partnership shall:

1) Process only those records and documents containing Confidential Information to which it has obtained access through business relationships;

2) Maintain clear identification of specifically protected information;

3) Strictly adhere to handling procedures for all records and documents containing Partner's confidential information.

2.6. The Partnership shall process the Users' personal data including but not limited to the following grounds:

- User's consent (pursuant to Article 6(1)(a) GDPR);

- Necessity for performance of a contract (Article 6(1)(b) GDPR);

- Legitimate interests of the Partnership (Article 6(1)(f) GDPR), including service improvement and fraud prevention;

- Compliance with legal obligations (Article 6(1)(c) GDPR).

3. Periods of Storage of Confidential information

3.1. Confidential Information shall be stored no longer than necessary to achieve the purposes of processing, or for the periods established by the laws of the Republic of Kazakhstan.

3.2. Confidential Information shall be destroyed at the User's request based on their application; or at the Partnership's discretion without explanation, by means of deletion.

4. Liability

4.1. The Partnership shall be liable for compliance with this Policy to the extent established by the laws of the Republic of Kazakhstan.

4.2. The User shall be responsible for the accuracy of provided information and the security of their account credentials.

4.3. The Partnership shall not be liable for potential risks and conditions of secure usage, or network attacks or website breaches, including but not limited to website malfunctions caused by technical issues.

4.4. Any and all disputes regarding Confidential Information between the Partnership and User shall be resolved in the manner stipulated in the Partnership's approved public documents and in compliance with the laws of the Republic of Kazakhstan.

5. Final Provisions

5.1. This Policy shall take effect upon approval and Remain valid until officially revoked.

5.2. The Partnership reserves the right to unilaterally amend or supplement this Policy at any time by publishing updated versions on the Website.

5.3. The Appendices form an integral part of this Agreement: A1 — Personal Data Collection and Processing Policy.